1EPA
guidance
on
baseline
years
is
found
in
the
memorandum
of
November
18,
2002,
from
Lydia
Wegman
and
Peter
Tsirigotis,
"
2002
Base
Year
Emission
Inventory
SIP
Planning:
8­
hr
Ozone,
PM2.5
and
Regional
Haze
Programs."
This
document
is
available
at
the
following
web
site:
http://
www.
epa.
gov/
ttn/
oarpg/
meta.
442.1.2002baseinv.
pdf.
That
document
noted,
"
The
EPA
is
aware
that
some
areas
have
already
begun
on
a
voluntary
basis
to
model
for
purposes
of
the
8­
hour
ozone
standard.
These
areas
may
continue
to
use
modeling
from
previous
base
years
for
each
set
of
meteorological
episode
conditions
for
use
in
their
SIP
submittals
if
these
studies
are
still
applicable
for
an
attainment
demonstration."
8/
16/
05
new
bump­
up
section
7.
What
baseline
emission
inventory
should
be
used
for
the
attainment
demonstration?
[
Not
addressed
in
the
June
2,
2003
proposal;
§
51.909
of
the
draft
regulatory
text.]
The
June
2,
2003
proposal
did
not
discuss
baselines
for
purposes
of
the
attainment
demonstration.
(
It
did,
however,
discuss
baselines
for
RFP
demonstrations.)
Section
51.909
of
the
draft
regulatory
text
provided
that
2002
should
be
used
as
the
baseline
emission
inventory
year
for
purposes
of
both
RFP
and
the
attainment
demonstration
for
areas
with
an
effective
date
of
designation
of
June
15,
2004.
We
recognize,
however,
that
some
areas
have
already
begun
to
perform
modeling
for
their
attainment
demonstrations
using
baseline
year
inventories
earlier
than
the
2002
inventory,
and
because
the
2002
inventory
may
not
be
in
a
format
to
readily
be
used
for
photochemical
grid
modeling.
1
Therefore,
the
final
rule
does
not
specify
a
baseline
for
purposes
of
the
attainment
demonstration
and
modeling.
As
discussed
more
fully
in
the
section
of
the
preamble
regarding
RFP,
the
specification
of
2002
as
a
baseline
year
for
RFP
purposes
(
for
areas
with
an
effective
date
of
designation
of
June
15,
2004)
appears
in
the
RFP
provisions
of
40
CFR
§
51.910.
Section
51.909
remains
reserved.
8.
Voluntary
Reclassifications
("
Bump­
ups").
Although
we
believe
most
8­
hour
nonattainment
areas
will
attain
the
standard
by
their
statutory
attainment
date,
we
recognize
that
some
areas
classified
under
subpart
2
may
need
additional
time
beyond
the
statutory
attainment
date
for
their
area
to
attain
as
expediously
as
practicable.
As
discussed
in
the
Phase
1
Rule
(
69
FR
at
23959,
col.
3),
in
the
event
an
area
cannot
practicably
attain
by
the
maximum
date
for
its
classification,
the
Clean
Air
Act
provides
the
opportunity
for
more
time.
An
area
regulated
under
subpart
2
can
receive
a
later
maximum
attainment
date
through
a
State
request
to
bump­
up
2Although
some
8­
hour
ozone
nonattainment
areas
have
additional
areas
beyond
the
boundary
of
the
former
1­
hour
nonattainment
area
and
thus
would
be
faced
with
new
requirements
for
the
higher
classification.

2
to
a
higher
classification
(
e.
g.
from
moderate
to
serious).
The
Act
requires
EPA
to
grant
a
State
request
to
reclassify
an
area
to
a
higher
classification;
the
State
plan
still
must
provide
for
attainment
as
expeditiously
as
practicable.
Although
bump­
up
means
that
certain
additional
specified
requirements
apply,
an
area
may
already
be
meeting
most
or
all
of
these
specified
requirements
due
to
controls
previously
adopted
to
implement
the
1­
hour
ozone
standard.
This
is
because
some
areas
had
1­
hour
classifications
that
were
higher
(
and
more
restrictive)
than
the
areas'
8­
hour
classification,
2
and
because
the
Phase
1
final
implementation
rule
for
the
8­
hour
O3
NAAQS
contains
antibacksliding
provisions
generally
requiring
areas
to
continue
implementating
measures
required
for
the
1­
hour
classification.
Although
there
may
not
be
additional
mandatory
control
measures
required
because
the
areas
may
already
have
such
measures
in
place,
an
area
that
needs
more
time
to
attain
may
need
additional
emission
reductions
to
reach
attainment.
E.
What
requirements
for
RFP
should
apply
under
the
8­
hour
ozone
standard?
[
Section
VI.
I.
of
June
2,
2003
proposed
rule
(
68
FR
32832);
§
51.909
and
§
51.910
in
draft;
§
51.910(
d)
in
final
regulatory
text.]
